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NEW TRANSFER PRICING TAXPAYERS IN PANAMA
During the last months of 2018, the following laws were enacted, which make transfer pricing studies mandatory.
- Law 52 of October 2018, "Which regulates the activity of call centers for commercial use (call centers) and dictates other provisions".
- Law 57 of October 2018 "Which amends Law 41 of 2007, which creates the special regime for the establishment and operation of the headquarters of multinational companies and the Commission on the headquarters of multinational companies and dictates other provisions".
- Law 69 of December 2018 "Which establishes the method for calculating the income subject to an exemption or preferential tax treatment for the transfer or operation of intangible assets and dictates other provisions".
The scope of these three laws, establish the obligation to conduct transfer pricing studies for the following taxpayers:
- Call Centers, even if their income is not taxable in Panama.
- Multinational Companies' Head Offices.
- Natural or juridical persons established or to be established in the Colon Free Zone, the Oil Free Zone under Cabinet Decree 36 of 2003, the Panama-Pacific Special Economic Area, the City of Knowledge or in any other free zones or in a special economic area established or to be created in the future, that carry out transactions with related parties that are established in the Republic of Panama or that are tax residents of other jurisdictions or that are established in any other special economic zone or area or subject to a special regime of the aforementioned.
